Shepherd v. Kennedy et al.

(Filed: Aug. 27, 2026)

Kelsey, a professional counselor born and raised in Spring Lake, Michigan, received a $75,000 student loan repayment grant from the National Health Service Corps ("NHSC") in 2022. However, because of her health needs and the needs of her family, she needed a job close to home, with a livable schedule. It wasn't until more than three years later that she finally learned that her new employer would not qualify as a Program site.

Right away, Kelsey offered to return the grant—every dollar of the $75,000. The NHSC refused to accept it unless she paid a fine of more than $250,000 on top of the $75,000. While her request to waive the penalty and remaining service obligation was pending, the government sent the debt she is actively contesting—more than $355,000 plus interest—to collections. Then, in April 2026, NHSC garnished Kelsey's 2025 federal tax refund of more than $3,500.

Kelsey argues that the fine and the government’s efforts to collect it violate the U.S. Constitution's Eighth Amendment Excessive Fines Clause and the Seventh Amendment right to trial by jury.


Filings

Complaint (Aug. 27, 2026)


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